Newby's Plastering, Inc. - Page 3

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          acquire jurisdiction when the Commissioner issues to a taxpayer a           
          notice of deficiency that reflects a "deficiency in respect of              
          any tax imposed by subtitle A or B", section 6212(a), and the               
          taxpayer timely petitions this Court to redetermine that                    
          deficiency.  Sec. 6213; Rule 13(a), (c); Keeton v. Commissioner,            
          74 T.C. 377, 379 (1980); Estate of Moffat v. Commissioner,                  
          46 T.C. 499 (1966).                                                         
               In the instant case, respondent has not determined a                   
          "deficiency in respect of any tax imposed by subtitle A or B".              
          Sec. 6212(a).  Respondent has determined only that petitioner is            
          liable for the three additions to tax mentioned above.  Pursuant            
          to section 6665, none of these additions to tax is treated as a             
          tax that is imposed by subtitle A or B.  As stated in section               
          6665:                                                                       
               SEC. 6665. APPLICABLE RULES                                            
                    (a) Additions Treated as Tax.--Except as otherwise                
               provided in this title--                                               
                         (1) the additions to the tax, additional                     
                    amounts, and penalties provided by this                           
                    chapter shall be paid upon notice and demand                      
                    and shall be assessed, collected, and paid in                     
                    the same manner as taxes; and                                     
                         (2) any reference in this title to "tax"                     
                    imposed by this title shall be deemed also to                     
                    refer to the additions to the tax, additional                     
                    amounts, and penalties provided by this                           
                    chapter.                                                          
                    (b) Procedure for Assessing Certain Additions to                  
               Tax.--For purposes of subchapter B of chapter 63                       
               (relating to deficiency procedures for income, estate,                 




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